nature of technical assistance by way of providing managerial, consultancy or technical services to the assessee. Technik performs the entire work on an inanimate object ... fees for technical services". The three type of services envisaged above also include the provision of the services of technical or other personnel
with reference to the services used in Section 44BB of the Act as the services rendered were purely for 'technical services' offered ... rendering of any managerial, technical or consultancy services (including the provision of services of technical or other personnel) but does not include consideration
person who has vast
technical knowledge and experience. Accordingly, the payment made to a
commission agent constitutes towards technical services."
10.2 Aggrieved the assessee ... foreign
agents rendered such services which are typical of any commission agency
business. Such services are not 'technical services' and therefore
fees received for technical services. Against these receipts, a sum of Rs. 61,02,120 was claimed as expenditure; so that the net income ... royalty and technical fee as income from two separate and distinct sources and debited expenses only against the fees receivable for technical services
payments received by the
assessee would qualify as "fee for technical services"as-defmed-
under section ... assessee from satellite transmission operations as
royalty/fee for technical services. The Ld. DRP also upheld the decision
of the Assessing Officer stating that
treated as 'royalty' and/or 'fees for technical services' as defined in Section 9 . In reply, detailed submissions were made ... nature of technical services and the payment received for such services was in the nature of 'fees for technical services'. The other activities
towards
management services fees to be in nature of fees for Technical
services („FTS‟) in terms of Article 13 of India-France Double Tax
Avoidance ... Services
Agreement is managerial services. It is plain that once the
expression "managerial services" is outside the ambit of "fee for
technical
this clause, the payments for rendering technical services, or
consultancy services, if such services make available technical
knowledge, experience, skill, know how or processes ... technical plan or technical design can
be charged to tax in India. In the case of the appellant the non
residents provided technical services
Services has been received on account of services rendered through a PE in
India and since in the case of assessee, the Fee for Technical ... 3675/Del/2014 & ors
the taxation of fee for technical services rendered. From the purchase orders,
the Assessing Officer observed that during the year
country
services and out country services as per contract with Aker. The submission
of the assessee that its in country services are taxable ... fees for technical services under Article 13 of India-UK as these services
do not make available any technical knowledge, experience, skill, know
